What's wrong with radio narrowcasting in Australia and how to fix it

Most mainstream media pundits dismiss the narrowcasting concept, and deride open narrowcast licences, particularly the low-power one-watt FM variety, as not being worth the paper they're written on. While I can't agree entirely agree with these sentiments, I readily admit there are shortcomings in the regulatory infrastructure for radio narrowcasting in Australia.

I dedicated my masters research project to investigating low-power radio narrowcasting in South East Queensland. When my study was completed last year, I had uncovered many interesting aspects - both good and bad - about this largely ignored, and perhaps poorly understood, sector of the media. My survey certainly showed that narrowcasting, as defined in the Broadcasting Service Act (BSA) has been given a stronger conceptual and regulatory foundation in Australia than in most other parts of the world.

This is no more evident than in the ACMA's (Australian Communication and Media Authority) recent discussion papers outlining a framework for narrowcast television in this country - a framework that is remarkably similar to that already in place narrowcast radio, as embodied in the “Narrowcasting for radio” (PDF 701KB) guidelines.

The purpose of this article is to highlight some areas in which I believe radio narrowcasting could be improved, so that the objectives of the BSA in regards to narrowcasting, namely, to enhance diversity in media in Australia, can be more fully realised. The information contained in this feature is derived largely from my own post-graduate research into and personal experience with radio narrowcasting. I suppose you could say I am writing a wish list of areas in which the government and ACMA could take action to make Open NarrowCast (ONC) licences more effectual and accessible to the public.

Hoarding

The biggest problem concerning radio narrowcasting is the extent to which licences are not being used. A government report investigating the problem of licence hoarding in 2000 suggested there was anecdotal evidence that up to 65 per cent of all Low-Power Open Narrowcast (LPON) FM were inactive. My own research shows that hoarding LPONs is still widespread, with some LPON licences having remained on the books but inactive for up to a decade.

Operators can get away with this because they often own several licences on a common frequency within close proximity to each other. They are thereby able to overpower one of those licences and create the illusion that all their LPONs are operating, when in fact they aren't.

The extent of narrowcast licence hoarding prompted the Minister for Communications in 2001 to issue a “use-it or lose-it” directive. However, the “use-it or lose-it” clause has in fact resulted in further concentration of ownership in this sector. Some larger narrowcasters, who were brazen enough to hold onto their existing portfolios, benefited from the ensuing “shakeup” when smaller owners sold their licences to avoid having then challenged and possibly cancelled.

The consolidation has left a few individuals and companies with very large holdings, and since these big players dominate the peak body ANRA (Australian Narrowcast Radio Association), it is unlikely that any of these mini media “moghuls” would challenge another other over the issue of hoarding.

The government's anti-hoarding strategem was only going to be truly effective if the ACMA had the gumption to initiate an audit in the aftermath of the directive's six-month start up timeframe. However, the ACMA was not and is not inclined to initiate any surveys of actual LPON and HPON usage, relying on a reactive public complaints mechanism to find and punish recalcitrant operators.

The end result is that the public is denied services that an owner has pledged to provide, thereby reducing the ability of narrowcasting to make a credible contribution to the broader media landscape.

The ACMA should initiate an audit of narrowcast licence usage in a key population area around a capital city - South East Queensland would be a good place to start - where there are many LPON FM licences allocated. An audit will reveal the extent of hoarding and other miscreant activities in the sector, and the ensuing widely publicised spate of licence cancellations and format breach notifications issued under Section 19 of the BSA, will make violators in other parts of the country more inclined to activate, trade or ultimately sell their licences to avoid the ignominy of having them cancelled.

LPON exclusion zones

The ACMA has established a mechanism or “planning model" (PDF 252KB) for allocating LPON FM licences. It includes requirements governing the spacing of licences depending on their frequency. The current Planning Model also creates “protection radii” around existing radio and TV stations, both for commerical broadcasters and the ABC, whose licensed FM frequency is close to the LPON frequencies - 87.6, 87.8, 88.0 Mhz.

These protection radii or “Exclusion Zones” (PDF 74KB) vary in size from 10km up to 160km, and they ban or partially ban the allocation of new LPONs within the area bounded by those circles. However, these same provisions permit those LPONs allocated under a planning model in the early 1990s to continue operation, despite the “risk” of interference with a more “senior” licensed broadcaster.

The protection radii imposed around channel 3 television stations are total bans on new licences, and these impact LPON FM licence allocations more than any other type of exclusion zone. Unfortunately for aspirant narrowcasters, these LPON bans prevent new applications in many areas.

It is my belief that these exclusion zones around channel 3 TV stations have passed their expiry date and should be lifted. In fact, this has already begun to take place. Last year the ACMA lifted a protection radius in North West Tasmania that had protected a channel 3 TV station which had ceased operating. As soon as ACMA announced the change, I acted swiftly to encourage my associates in that region to make several applications for new LPONs. The result was three new LPON FM stations in the greater Launceston area on 88 FM. There was a fourth application which went to auction under the price-based allocation system, which was applied to narrowcast licences in 2001.

More applications have been made in the 12 months since the ban was lifted, and many licences that were being hoarded have been activated in response to the new competition in that market. This should serve as an illustration of the likely demand for LPONs once these restrictive bans are removed from around these TV stations. As these TV stations become increasingly reliant on their simultaneous digital broadcasting, the protection of their analogue signals will be less important (if it ever was!), thereby justifying the release of the FM spectrum used by low-power narrowcasting.

Even while it was in place, the large Tasmanian exclusion zone allowed more exemptions than any other LPON exclusion zone in the country, which in itself demonstrates that such zones are not essential to protect channel 3 TV signals from interference. I estimate that the lifting of these bans could facilitate the allocation of over 100 new LPON FM licences that would reach key population centres.

The government should lift the exclusion zones around all channel 3 TV stations immediately, and allow applications for new LPON FM licences to be submitted for the August round of allocations. It will take up to six months from September 2007 before any newly allocated licences are activated, thereby giving the TV licence owners time to accelerate their switch to digital format broadcasting. And even if that doesn't occur, the risk of interference with their continuing but increasingly less important analogue channel 3 transmissions, will be negligible. And if the government is determined to maintain some form of LPON Ban around these TV stations, then at least they can direct ACMA to immediately reduce the “protectionist” radii by half.

Narrowband Area Service Stations (NAS-MF)

Narrowband AM licences are allocated to medium wave (MF) frequencies ranging from 1611 Khz to 1701 Khz, just above the recognised AM broadcast band. Rated at 400 pZ (400 Watts), these licences permit transmissions that could cover a much larger area than even a local area network of LPON FM stations, and larger than many HPON FM licences. Some of these narrowband licences have been granted an S40 classification, allowing them to operate as out-of-band commercial radio stations.

Those licences that do not qualify for S40 status are deemed to be Open Narrowcast (ONC) licences transmitting in the “Extended AM Band”. This area of the AM spectrum is widely used in the United States. However, in Australia, this band has been poorly utilised to provide services that could otherwise engage the public at large. I believe there are a few reasons for this.

1. A new NAS-MF licence issued by ACMA will cost less than a new HPON licence, which carry a $4,000 reserve price tag. NAS-MF licences can command comparable purchase prices to HPONs on the open market, even in capital cities. However, the start up cost for establishing a NAS-MF station to exploit the full potential of the licensed power is quite high, being in the order of at least $60,000 - $80,000. A minimal equipment configuration could be installed for perhaps as little as $15,000, but the coverage radius will be smaller. This is still considerably more than the cost of setting up a typical HPON FM of similar power.
    
2. There is no anti-hoarding provisions in regards to NAS licences. This results in widespread abuse of this resource, which in turn leaves the public without an opportunity to hear a narrowcast service that might work well on these exotic frequencies. Following the demise of “Radio 2” about a year ago, the only narrowband station I have heard consistently in Brisbane is Hindi Language station Radio Brisvaani on 1701 Khz. The other frequencies simply do not appear to be being used regularly, if at all.
    
3. Radio receivers available from consumer retail outlets rarely tune to the “Extended AM Band” frequencies. Therefore, even if most of these stations were on the air around the clock, only a small portion of the potential audience would be able to tune into the signal on commonly available radio sets, including those installed in cars.
   
   My investigations into the availability of radios that will tune to these higher AM frequencies has revealed that some, perhaps half, will go as high as 1629 Khz, but very few will reach 1701 Khz in 9 KHz steps. It is therefore no suprise that more than 50 per cent of the MF-NAS licences in Australia are allocated for frequencies between 1611 Khz (the most common) and 1629 Khz, and most of those are S40 category commercial licences. This reality tends to negate the notion of these licences being open narrowcast, since the signals are not readily and openly available on common radio equipment - a fact that ACMA acknowledges.

Hoarding of NAS licences is a big problem and the government can explore different mechanisms of compelling owners to activate licences. A “use-it or lose-it” directive, followed up by an ACMA audit of these licences, might encourage a realignment in the sector which would see more of these licences activated. The public would then at least have the opportunity to listen to an array of niche program services. However, because so few radios in Australia can tune to these frequencies, we have conditions that might qualify as market failure. Therefore, the government should intervene to encourage electronics companies to provide radios that tune across the full range of AM and FM frequencies, including those licensed for out-of-band narrowcasting.

Finally, the best thing that the government could do to empower this fourth tier of radio broadcasting in Australia is to allow a conversion to digital radio. By opening to narrowcast operators, both FM and AM, that doorway to the future of radio, the sector will respond to the opportunities provided by new technology, and the Australian public will be the better served for it.